Your information
Actiiv privacy notice
For members, coaches and everyone who uses Actiiv.
Interim notice, under review. Draft prepared 27 September 2026, updated 5 and 18 October 2026, and awaiting solicitor review; words in [square brackets] are still to be settled, and parts marked "when switched on" describe features that are built but not switched on yet.
1. Who we are
Actiiv ("Actiiv", "Actiiv Club", "we", "us") is a trading name of FLIP OPERATING SYSTEMS LTD, a company registered in England and Wales under company number 17370395. Registered office: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF.
We run:
- the Actiiv Club member app at actiiv.club (including Coach mode for coaches on their phone);
- the coach app at coach.actiiv.club;
- our website actiivclub.com and its waitlist;
- lead pages we host for coaches (for example <name>.actiiv.club and actiiv.club/c/<name>);
- payment pages at actiiv.club/pay.
For most of what this notice covers we are the controller: we decide why and how your information is used. If you train with a coach, your coach also uses some of your information for their own business; section 9.1 explains what they can see. How responsibility for a client's coaching records is shared between us and the coach is still being settled: the coach terms (section 13.1) and the terms for coaching bought through Actiiv (section 10.1) currently describe the coach as the controller of those records.
Contact: actiivclub@gmail.com
2. The short version
- You tell us about your training, food, body, health and wellbeing so the app can coach you. Much of this is health information, which the law treats as especially sensitive. We use it to run the app for you.
- The in-app Coach is an AI. To answer you, parts of your information are sent to Anthropic (the company behind the Claude models). Photos of gym machines go to OpenAI first. Neither is sent your email address.
- If you join a coach, they can see your training, food and daily logs, body stats, check-ins, runs, sports, health profile and what the AI Coach has noted about you. They cannot see your journal, affirmations, to-dos, vision board or cycle tracking. They see your progress photos only if you choose to share them (section 4.7), and you can stop at any time.
- Card payments are taken by Stripe. We never see your card number.
- We don't sell your information, show adverts, or use advertising or analytics trackers.
- Using your injuries, medical conditions and the AI Coach's health notes needs your separate, optional consent (when switched on), which you can withdraw at any time (section 5).
- In the app, under Me → Privacy & your data, you can download your information, see and delete what the AI Coach remembers, give or withdraw health-data consent, and delete your account (when switched on). For anything else, email actiivclub@gmail.com.
3. Who this notice covers
- Members of Actiiv Club, whether you train on your own with the AI Coach or with a coach.
- Coaches who use the coach app.
- People who fill in a coach's consultation form on a lead page we host.
- People who pay a coach through a payment link without an Actiiv account.
- People a coach invites to Actiiv through the coach's Assistant, before they join (when switched on; section 4.14).
- People who join our waitlist.
4. What we collect
4.1 Your account
- Your email address and password. The password is stored by our database provider in scrambled (hashed) form; we cannot read it.
- If you choose Continue with Google, Google shares your name and email address with us. We never see your Google password.
- Your name, as you type it.
- Whether you are a member, a coach or a member of the Actiiv team, and when you joined.
4.2 Your profile
From the questions when you join, and from Me afterwards:
- sex (woman, man or prefer not to say) and age band;
- date of birth (optional), height, weight and target weight;
- goals, training experience, activity level, days a week, session length, where you train and your equipment;
- injuries (optional free text), allergies, diet preference and supplements you use;
- protein and calorie goals.
Most of this is saved to your account. Your age band stays on your device, but is included in what the AI Coach sees (section 7).
4.3 Training, food and daily logs
- Your workouts and programmes, every set you log (reps, weight, time), personal bests, and exercises you save to your own library.
- Your food log: what you ate, calories, protein, carbs and fat, and how you logged it (quick add, photo, barcode, search or recipe).
- Daily numbers you enter: steps, water, sleep, mood (1 to 5), energy (1 to 5) and habits ticked. The app does not read these from a health app or wearable; you enter them yourself.
- Body weight and body measurements.
- Your food quiz answers and your meal plans (your own, or one your coach gives you).
- The targets you set.
4.4 Your health and preferences
Under Me → Health & preferences: allergies, intolerances, diet, foods you dislike, injuries (body area and side), medical conditions and notes. These come from you, from the AI Coach when you mention something in a chat (it asks you to confirm or remove it), or from your coach. They are used as safety rules: for example, a meal plan containing one of your allergens is refused.
4.5 Cycle tracking
If you use it: the days you mark as your period (with the flow, if you choose one), the symptoms and moods you tick from a fixed list, any short note you add to a day (up to 280 characters), and your usual cycle length (whether the fertile window is shown is kept on your phone only). We keep up to about ten years of days. This is used to show your cycle day, your phase and estimates of your next period, fertile window and ovulation (not contraception or medical advice). Under 18, the fertile window and ovulation are never shown. It is saved to your account and is private to you: your coach cannot see it, and it is not sent to the AI Coach or anyone else. Wellness → Cycle → Delete my cycle history deletes all of it from your account and that phone.
4.6 Your Mind space
Journal entries (text and mood), affirmations, to-dos (with reminder times) and vision board pictures and captions. These are saved to your account and are private to you: your coach cannot see them. Some are used by the AI Coach (section 7).
4.7 Photos, camera and microphone
- Progress photos (front, side, back, with the date): uploaded to private storage in your account. Only you can see them, unless you choose to share them with your coach. Sharing with your coach (Progress → Progress photos) is off until you turn it on, is offered only while you are with a coach and are 18 or over by the date of birth on your account, and covers all your progress photos, old and new, with the date each was taken. We record when you turn it on and off, the version of the wording you saw, and when your coach last looked. Your coach sees the photos in their app only, as pictures loaded one at a time with their own login; no link to a photo is ever made that could be passed on. Turn it off at any time: your coach loses access straight away (a screen already open clears within about 30 seconds). It also ends by itself if you leave your coach, your coaching is paused, or the date of birth on your account shows you are under 18. A new coach never inherits it.
- Vision board pictures: uploaded to private storage in your account. Only you can see them.
- Photos you scan (a meal, a food label or a gym machine) are sent for analysis (section 7). We don't keep the photo, unless it is a photo of a packet's nutrition table that you add to the food index (section 4.17).
- Share cards (your run, session or stats over a photo) are made on your device and shared through your phone's own share menu. We don't upload them.
- Video and voice messages with your coach (section 4.9) use your camera and microphone only while you record.
4.8 Runs and your location
When you start a run, the app uses your phone's location (after you allow it) while the screen is on. For each run you save we keep:
- the route: up to 2,000 points, each with latitude, longitude, time and accuracy;
- pauses, distance, time, pace and an estimate of calories burned.
Your coach can see your runs, including the route on a map. The start screen tells you this. If you discard a run, it is not saved.
The map pictures come from the OpenStreetMap servers. Your device asks them for the map of the area around the run, so they receive your device's internet (IP) address and that area.
4.9 If you train with a coach
- The link itself: which coach, when you joined, and whether you have a place.
- Weekly check-ins: energy, sleep, stress and nutrition (1 to 5), sessions done and planned, your weight, and your wins, struggles and questions. Your coach's reply, which may be a video. An AI-written summary and draft reply for your coach are stored with the check-in (section 7).
- Messages with your coach: text, video clips (up to 60 seconds from you, up to 120 seconds from your coach), voice notes, and when each was read.
- Your schedule and bookings (session times and whether you attended).
- Challenges: your points, worked out from your workouts, check-ins, steps, water, sleep and sessions attended.
- Groups: your posts and reactions. In groups set up for it, the app posts automatically when you finish a workout ("[first name] finished [workout]"), with no personal bests or health numbers.
- Your coach's private notes about you. You cannot see these.
- Alerts the app shows your coach, such as a missed check-in, no workouts in 7 days, low completion or weight off track, and from your check-in answers low energy, poor sleep, high stress, nutrition slipping or wanting a call.
- A record of what you owe and have paid your coach (section 8).
4.10 The AI Coach
- What you type to it. The conversation is kept on your device for the current session (the last 20 messages) and cleared when you sign out. We do not store your chat in our database.
- Things the Coach learns about you: short notes (for example a health issue, an injury, a dislike, a preference or a goal) saved to your account and used in later chats. You can see them in Me → Privacy & your data and delete them there (when switched on), and the Coach won't save a deleted note again. Your coach can read them too, apart from health and injury notes when your health-data consent is off (section 5).
- How many times you used it each day (there is a daily limit).
4.11 Notifications
If you turn on notifications:
- the subscription your browser gives us (an address and encryption keys for your device), your time zone, and the time you want your daily affirmation;
- a record of each notification we sent (its type, a reference and the time), so nothing is sent twice.
Notifications are delivered through your browser maker's push service (Apple, Google, Mozilla or Microsoft). The message content is encrypted so that service cannot read it. A notification may show on your lock screen, for example a to-do's text, your affirmation, or "[first name] sent you a message". You can have up to 5 devices; adding a sixth removes the oldest. A coach who turns on reminders in the coach app has devices and reminders of their own (section 4.14).
Rest alerts in Train. If notifications are on for your device and you lock your phone or leave the app during a rest between sets, the app sends our server how long the rest has left, your device's subscription address and keys, and the name of your next exercise. Our server keeps these only until the rest ends, sends one notification ("Rest's up", then "Next: Squat" or "Time for your next set"), and then deletes them. The exercise name is only included for exercises from our library, never for your coach's own or your own. Nothing about your sets, weights or health is sent. To count fair use we also keep, for the day, a coded reference to your account and how many rest alerts it used.
4.12 A coach's consultation form (lead pages)
If you fill in a consultation on a coach's lead page we collect:
- your name, an email address and/or phone number, and your Instagram handle (optional);
- your age range and town or area (optional);
- what you are interested in, your goals and what you'd like to achieve in three months;
- how active you are, your experience, how you feel walking into a gym, where and when you'd like to train;
- how you eat, food notes, sleep, your weekly routine and stress;
- health answers: injuries, medical conditions or medication, and whether you are pregnant or postnatal, with any details you give;
- what you've tried before, anything else you want to say, and where you heard about the coach;
- your ticks: that you are 18 or over, that you agree to your details going to the coach, and (if you gave health answers) that you agree to share your health information with the coach;
- the website that sent you to the page (its name only, for example instagram.com) and whether you used a phone, tablet or computer.
Health answers are only stored if you tick the health consent; without it they are refused. Only that coach can read your consultation. The consent line on a lead page does not link to this notice yet; it is at actiiv.club/privacy.
While you fill in the form, your answers are kept in your browser tab so you don't lose them, and cleared once sent. We also count how many people visit each lead page per day, by referring website and device type. We don't identify visitors: no IP address, cookie or device identifier is stored for a visit.
4.13 Waitlist
Your email address, where you came from (a referral code, or the name of the website that linked you) and, if you tap it on the form, whether you are a coach, a gym or training yourself.
4.14 If you are a coach
- Your account and coach profile: business name, handle, bio and photo.
- Your programmes, templates, meal plans, exercise library (including videos you upload), the cover photos you put on programmes (ours, or one you take or upload), availability and session types, and your lead page statistics. A cover photo you upload is kept in private storage under your account; only you and the clients who hold that programme can see it. It is kept until you remove it or delete the programme, and deleted if your coach account is closed. We never send it to an AI provider.
- "My voice" writing samples, if you add them, used by the Assistant to draft in your style.
- Your planner: the things you add to your own Schedule (a title, notes, the day and time, repeats and whether it marks you busy). Your clients never see them, and they are kept until you delete them.
- Reminders (if you turn them on in the coach app): the coach-app devices you allow (up to five, each with its time zone and the address and keys your browser gives us), your reminder choices, and the next times of your own planner items with their titles, so a reminder can be sent. A reminder can show an item's title, or a session's type and your client's first name, on your lock screen; it never carries a note, a health detail or an amount. Times more than a day old are cleared as the app syncs your planner.
- How often you use the Assistant and the check-in digest each day.
- For card payments: your trading name, postal address and contact email (shown to your clients), your Stripe account's identifier and status, the terms version you accepted and when, your fee plan and your seat plan.
- We don't ask for your tax details or report your earnings to HMRC: see HMRC and platform reporting. If you gave us seller tax details before 18 October 2026, we still hold them, encrypted, and use them for nothing; [what happens to them is still to be settled].
- People you invite (when switched on). When you invite someone through the Assistant, we keep their first name, and their surname and email address if you add them, with what you plan to start them on (a programme, when to start, a check-in day, a meal plan and a short note) and, if they filled in your consultation form, a link to it. Only you see it: it is never shown to the person you invite, and their email address is never checked against anyone's account. We don't email them; the address only fills in the "To" line when you send the invite from your own email app, and if you send it by WhatsApp your phone passes their number and the message to WhatsApp (we don't keep the number). When someone joins you and you confirm it is them, the invite is linked to their account so the Assistant can set them up; they don't see it. What you type to the Assistant about them, such as their name, goes to Anthropic with the rest of your message (section 7). An invite that has been cancelled, or has run out, is deleted 30 days later, and one that has joined is deleted 30 days after you finish setting them up; one that has joined and is never set up stays until you delete your account. The clean-up happens the next time you save, cancel, link or finish setting up an invite.
The coach app keeps some working information in your browser, such as your current Assistant conversation (for that session) and today's job list.
4.15 Technical information
When your device connects, our hosting provider (Netlify) and database provider (Supabase) receive its IP address and browser details, as with any website. How long each of them keeps its own access logs is still to be confirmed. Our own server logs are written to record errors and timings, not names, email addresses or health details.
On payment pages, we count requests per IP address to stop abuse. The address is turned into a one-way code using a secret key and that day's date; the address itself is never stored, and the code is deleted after a day.
4.16 Problem reports and feature suggestions
If you report a problem or suggest a feature in the app (when switched on), we keep what you write, where in the app it happened, the app version and one short line about your device (for example "iOS 17 · Safari 17 · installed"). The app shows you all of this before you send it. We never take a screenshot or anything else from your phone. Only the Actiiv team reads it, never your coach. With it, the team sees your first name and your coach's business name (your own, if you are a coach), never your email address. We keep it while we deal with it. About 12 months after it is marked done the team deletes it, by hand, about once a month, so it can stay a little longer; one that is never marked done stays until it is. You can ask us to delete one at any time, and deleting your account deletes all of them.
4.17 Adding a product to the food index
If you scan a barcode the app doesn't recognise, or one with no nutrition information, you can add the product for everyone (when switched on). We keep the product's name, brand and nutrition numbers that you check and save, and the photo you take of the packet's nutrition table, if you take one (you can type the numbers in instead). The photo is read by AI to fill in the numbers for you (section 7) and, when you save, kept in private storage. Only the Actiiv team sees the photo, with your first name, to check the numbers; you can't open it again yourself. Other members see the product and its numbers, never the photo or your name. Please photograph the packet only: no faces, no people, no rooms.
The product is kept in Actiiv's food index for everyone. If you delete your account, the products you added and their photos stay in the index, with nothing that names you, though a photo's file name holds the reference number your account had. If the team turns an entry down, its photo is deleted. You can ask us to delete a photo at any time.
If you answer "Does this match your packet?" about a product someone else added, or send a fix, we keep your answer with that product, linked to your account but shown to no one else (the team sees only how many answered and what numbers a fix suggests, never who sent them), until you delete your account. When you scan a barcode, the app looks in Actiiv's index before Open Food Facts; we count how often a product is found there, not who scanned it.
4.18 Sports you track
In Run, under Your sports, you can add the sports you play or track (for example tennis, padel, Pilates or yoga). For each sport we keep the days you usually play and whether each is a match, a lesson or a social game, whether you are in or out of season, and whether you use its gym or home strength sessions. When you log a game, lesson or class we keep the day, the kind, the minutes, how it felt (1 to 5) and an optional short note (up to 280 characters). These are kept on your phone first and then saved to your account. Your coach can read them while you are their client (the coach app does not show them yet). The AI Coach is sent your sports, their season, kit and play days, this week's sessions and how many games you logged this week, never your notes (section 7). Removing a sport keeps the games you logged for it as your history until you delete them; deleting your account deletes them all.
5. Health information and your consent
Much of what you record in Actiiv is health information ("special category data" under UK data protection law): your training, food, weight and measurements, sleep, mood and energy, injuries, allergies and conditions, cycle tracking (period days, flow, symptoms, moods and notes), check-in answers, what the AI Coach learns about your health, and photos of your body. For people who fill in a consultation form, it includes injuries, medical conditions, medication and pregnancy.
We use health information only to run Actiiv for you: to track your progress, keep you safe (for example allergy and injury rules), power the AI Coach, and, if you choose a coach, let them coach you.
Your consent for health details (when switched on). Separately from accepting our terms, we ask for your explicit consent before we use your injuries, medical conditions and the health and injury notes the AI Coach keeps about you. With it, Actiiv, your coach and the AI Coach use them to coach you safely. The choice is an optional, unticked box on the terms screen you see after signing in, and it is only for members 18 or over. You can use Actiiv without it. We record each choice with the time, the version of the wording you saw and where you made it. We don't record your IP address or device.
Withdrawing (when switched on). You can withdraw at any time in the app: Me → Privacy & your data → Health-data consent → Withdraw consent. While your consent is off:
- your injuries, conditions and the AI Coach's health and injury notes are hidden from your coach (including their Assistant and check-in digest, section 7) and from the AI Coach;
- no new ones are recorded: not when you join, not from AI Coach chats, and not by your coach;
- what you saved before stays in your account, shown only so that you can delete it (in Me → Health & preferences, or all at once with Delete saved injuries and conditions under Privacy & your data);
- nothing else changes, and nothing is deleted unless you delete it.
Withdrawing doesn't affect what we did before. You can give consent again in the same place. Accepting new terms never changes your choice.
The rest of your health information (training, food, weight and measurements, sleep, mood and energy, allergies, cycle tracking, check-in answers and photos of your body) is used to run the features you use, whether or not this consent is on. Sharing progress photos with your coach is a separate choice of its own (section 4.7): it is never part of this consent and never turned on by it.
6. Why we use your information, and our lawful basis
| What we do | Information used | Lawful basis (proposed; for the solicitor to confirm) |
|---|---|---|
| Create and run your account, save your data and sync it across your devices | Account, profile, logs | Contract: we need it to provide the app you signed up for |
| Use your health information to run the app and keep you safe | Section 5 | Contract, plus your explicit consent for the health information (when switched on; until then [basis to be settled]) |
| Power the AI Coach (answers, plans, meal plans, food estimates, machine scans) | Section 7 | Contract, plus your explicit consent for health information (when switched on; until then [basis to be settled]) |
| Let your coach see your information and coach you | Section 9.1 | Your request when you accept a coach (contract), plus explicit consent for health information (when switched on; until then [basis to be settled]) |
| Track and save your runs | Route and run stats | Contract (you start each run). Whether consent is also needed is still to be confirmed |
| Send notifications you turn on | Push subscription, reminder times | Consent (given in your browser; switch off any time) |
| Take card payments, keep payment records and send the emails consumer law requires | Section 8 | Contract; legal obligation |
| Hold the seller tax details some coaches gave us before 18 October 2026 (not used for anything) | Section 4.14 | [basis to be settled] |
| Check that people paying by card are 18 or over | Date of birth | Legal obligation / legitimate interests [confirm] |
| Keep Actiiv secure and prevent abuse (daily limits, bot checks, request counting) | Technical information, usage counts | Legitimate interests: keeping the service safe and affordable |
| Pass a consultation to the coach you contacted | Section 4.12 | Consent (the tick on the form), plus explicit consent for health answers |
| Count visits to lead pages | Daily totals by website and device type | Not personal information (no visitor is identified) |
| Email you from the waitlist | Consent |
We don't use your information for advertising, and we don't sell it.
7. The AI Coach and other AI features
Actiiv uses AI from two providers. They process your information to produce an answer and send it back; we don't send them your email address.
| Feature | Sent to | What is sent | What is never sent |
|---|---|---|---|
| Coach chat, "build me a plan" and meal plans (member app) | Anthropic (Claude) | What you type; your name, sex, age band, date of birth, height, weight, goals, experience, schedule, equipment, injuries, diet and supplements; recent sessions, workouts and personal bests; today's steps, water, sleep and energy; protein and targets; latest weight; your health and preferences; what the Coach has learned about you; your last 6 journal entries (first 280 characters each) with mood; open to-dos; active affirmations; how many vision board pictures you have; your food quiz answers and meal plan; your sports (each sport's season, kit and play days, this week's sessions placed around them and how many games you logged this week) | Email address, cycle tracking, progress photos, vision board pictures, runs, notes on the games you log, messages with your coach |
| Food photo or food description | Anthropic (Claude) | The photo or text, and the profile and logs above, but not your journal, to-dos or affirmations | As above, plus journal, to-dos and affirmations |
| Reading a food label for the food index (when switched on) | Anthropic (Claude) | The photo of the packet's nutrition table only | Anything about you |
| Barcode scan | Open Food Facts (not AI) | The barcode number only, asked for directly from your device or, if that is blocked, through our server, which passes on nothing but the number | Anything about you |
| Gym machine scan | OpenAI first; Anthropic if OpenAI fails | To OpenAI: the photo, your goals, experience, whether the app speaks to you as a woman, a man or neutrally, days a week, and the body areas of any active injuries. If it falls back to Anthropic: the photo plus the information listed for food | To OpenAI: name, email, journal, to-dos, affirmations, learned notes, cycle tracking, free-text injury notes |
| Check-in digest (coach app) | Anthropic (Claude) | Your check-in answers (this week's and last), your first name, goal, experience, schedule, injury note, recent weights, a training and food summary, your coach's notes and alerts | Email address |
| Coach Assistant (coach app) | Anthropic (Claude) | The coach's business overview (clients' first names, status and alerts) and, when the coach asks about a client, the parts that request needs: the client's first name, programme and training, progress, check-ins and messages with the coach, health and preferences if the client has chosen to share them with the coach, and the coach's private notes; the coach's own writing samples and templates; and what the coach types to it, which can include the name, email address or phone number of someone they are inviting. | Dates of birth, progress photos, cycle tracking, run maps. |
What the AI suggests is advice, not a decision about you. It can change things in the app only when you ask it to (for example "log my water"), and its suggestions to coaches are cards the coach approves, edits or skips.
We ask OpenAI not to store scan requests (the request is sent with storage switched off). If our own OpenAI key were ever unavailable, scan requests would go to OpenAI through Netlify's AI gateway instead. How long each provider keeps requests, and that neither uses them to train its models under the business terms in place, is still to be confirmed.
8. Payments
Card payments are processed by Stripe. You enter your card details on Stripe's own page, never in Actiiv, so we never see your card number. When you pay a coach, the payment is made on the coach's own Stripe account, in the coach's name. No health information is sent to Stripe.
What we keep:
- what you bought, the amount, dates, status, refunds and disputes, and Stripe's reference numbers;
- the terms version you agreed to, your confirmation that you are 18 or over and, where asked, your request for the coaching to start straight away;
- a link between your account and the customer record Stripe holds for you on your coach's account.
What goes to Stripe: your email address (for your Stripe receipt), what you are buying and the amount. Your coach can see your payments, and the email address you paid with, in their own Stripe account.
Payment emails (confirmations, cancellations, reminders the law requires, failed payments) are sent by our email provider Resend from payments@actiiv.club. They include your email address, your coach's trading name, address and email, what you bought and the amount.
Paying through a payment link without an account: we collect your name and email address and ask for your date of birth to check you are 18 or over. The date of birth is checked, not stored. Your coach sees your name, email address and payment. We use your email to send your receipt and your manage-or-cancel link. We blank your name and email 12 months after your last payment, plan end or refund window, unless you create an account and link the payment to it; the payment record itself is kept. You can ask for your details to be removed sooner from the manage page, except while a refund or your 14-day cancellation period is still open.
The page you pay on has its own short "How your details are used" section; this notice has the full detail.
Coaches' seat plans are billed on Actiiv's own Stripe account, using the coach's email and business name.
9. Who can see your information
9.1 Your coach
If you accept an invitation from a coach, while you are their client they can see:
- your name, date of birth, sex, height, weight, target weight, goals, experience, schedule, equipment, injury note, diet and supplements;
- your workouts, sets, personal bests and training history;
- your food log, food quiz answers and meal plan;
- your daily steps, water, sleep, mood, energy and habits;
- your weight and measurements;
- your health and preferences (allergies, intolerances, diet, dislikes, injuries, conditions), which they can also add to or edit;
- your runs, including routes on a map;
- your sports and the games you log, with any note you add (your coach's account can read them; the coach app does not show them yet);
- your check-ins, messages, bookings, and your place in their challenges and groups;
- your payments to them;
- the notes the AI Coach keeps about you (section 4.10).
If your health-data consent is off (section 5), your coach does not see your injuries, conditions or the AI Coach's health and injury notes, and cannot add new ones.
Your coach cannot see your journal, affirmations, to-dos, vision board, cycle tracking or your AI Coach chat, and cannot see your email address in the app. They see your progress photos only while you choose to share them with them (section 4.7).
If you leave your coach (Me → Your coach), they stop seeing your logs, runs, health profile and check-ins straight away. Your message history stays readable by both of you, and your coach keeps their own notes and the payment records.
9.2 Other members
- In a challenge, everyone taking part sees first names and points.
- In a group, members see each other's first names, posts and reactions, and the automatic "finished a workout" posts.
9.3 The Actiiv team
A small number of authorised Actiiv team accounts can read account, profile and client records for support, safety and to meet legal duties, and can see reports of payment links. They can also see:
- member by member, when you joined and last used the app and how many workouts, runs, food entries, weigh-ins and days you have saved, with your first name and your coach's handle (never your email address, your numbers, your food or your routes), to check that the app is saving everything;
- the problem reports and suggestions you send (section 4.16, when switched on);
- the label photos added to the food index, with the first name of the member who added each, to check the numbers; they can delete them (section 4.17, when switched on).
Of the photos and files members upload, these label photos are the only ones a team account can open in Actiiv's apps: the team cannot open your progress photos, vision board pictures, or the videos and voice notes in your messages. Who has access to the administration tools of our database, and how that access is controlled, is still to be confirmed.
9.4 Service providers who work for us
They handle information only to provide their service to us.
| Provider | What they do for us | What they receive | Where | Safeguards |
|---|---|---|---|---|
| Supabase | Database, file storage, sign-in, live messages | Everything saved to your account | Stored in an Amazon Web Services data centre in Frankfurt, Germany (region eu-central-1, confirmed from the project settings). [Confirm whether Supabase staff or subprocessors outside the UK/EEA can access it.] | UK adequacy for the EEA; [data processing agreement: confirm] |
| Netlify | Hosts our websites and runs our server functions (AI requests, payments, notifications, emails); keeps rest alerts in its storage until the rest ends (section 4.11) | Every request, including your IP address and what the function passes on | We do not set a region for our functions; where they run is still to be confirmed | [Confirm DPA and transfer safeguard; confirm whether Anthropic requests also pass through Netlify's AI gateway, as OpenAI scans would if our own key were missing] |
| Anthropic | AI for the Coach, check-in digest and Assistant | Section 7 | [United States: confirm] | [Confirm commercial terms, DPA, retention and transfer safeguard] |
| OpenAI | AI for gym machine scans | Section 7 | [United States: confirm] | Storage of the request switched off; [confirm DPA, retention and transfer safeguard] |
| Resend | Payment emails | Email address, coach's trading details, what was bought, amount, dates | Ireland (region eu-west-1, from its sending-domain settings) | [Confirm DPA and transfer safeguard] |
| Push services (Apple, Google, Mozilla, Microsoft, depending on your browser) | Deliver notifications | Your device's subscription address and the encrypted message | [Various] | Message content encrypted end to end |
| OpenStreetMap tile servers | Map pictures on runs | Your IP address and the map area | [Confirm] | [Pilot only; see section 4.8] |
Open Food Facts, a free public food database, receives the barcode number when you scan a barcode, and your IP address when your device asks it directly (if that is blocked, our server asks and it sees our server's address instead). The picture of a scanned product loads from its image servers, which see your IP address. We don't send it anything about you.
jsDelivr, a public content network, serves the pictures in the exercise library as you browse exercises, and Shopify's image network serves the product pictures in the Shop tab when you open it. Your device asks each of them for the picture directly, so they see your IP address and which picture you asked for. We don't send them anything about you.
9.5 Others
- Stripe acts as its own controller for payment and identity information (for example when a coach sets up a Stripe account). See https://stripe.com/gb/privacy.
- HM Revenue & Customs: we report coaches' seller details and the payments they received through Actiiv, as the law requires.
- Legal reasons: we may share information if the law requires it, to protect someone's safety, or to deal with a legal claim.
- If our business changes hands: information may pass to the new owner, who must keep to this notice.
10. International transfers
Your account data is stored in Frankfurt, Germany, which the UK recognises as giving adequate protection. Some providers (Section 9.4) are based in, or may process information in, the United States. Where information leaves the UK or EEA we will rely on [the UK International Data Transfer Agreement / the UK Addendum to the EU standard contractual clauses / the UK-US data bridge, for providers certified to it]. Which of these applies to each provider is still to be confirmed. You can ask us for details.
11. How long we keep your information
| Information | How long |
|---|---|
| Your account and everything saved to it | While your account is open. There is no automatic deletion today, and we have not yet decided what happens to inactive accounts |
| Things you delete in the app (journal entries, to-dos, affirmations, vision board pictures, progress photos, health and preference items, runs, measurements, your own workouts and exercises, sports and the games you log, AI Coach notes) | Deleted from your account when you delete them. For a deleted AI Coach note we keep only a one-way code of its text, so it is not saved again |
| A coach's programme cover photos | Until the coach removes the photo or deletes the programme it is on; the coach app then removes the file. Photos that nothing shows any more (a closed browser tab, a deleted client account) are cleared by us by hand, from time to time (there is no automatic job). All of a coach's photos are deleted when the coach's account is closed |
| AI Coach chat | On your device for the current session only (last 20 messages); cleared when you sign out |
| Information on your device | Until you sign out, which removes your logs and profile from that device (your theme and other settings, and a copy of your food preferences and own meal plan, stay until the next sign-in or until you delete your account), or clear your browser data. If your sign-in ends some other way (it expires, or it is ended in another tab or elsewhere), the saved copy stays on that phone until you next sign in; a different account that signs in there starts clean and never sees it |
| Messages with a coach, and your coach's notes about you | Kept after you leave the coach; no automatic deletion, and we have not yet set a period |
| Consultation form answers | Until the coach deletes them (the coach can delete one at any time). We have not yet set a maximum period |
| Problem reports and feature suggestions (when switched on) | While we deal with them; the team deletes them about 12 months after they are marked done (by hand, about once a month), sooner if you ask, and with your account |
| Products you add to the food index, and their label photos (when switched on) | Kept in the index for everyone, also after you delete your account (with nothing that names you). A photo is deleted when the team turns its entry down, or when you ask |
| Your answers about food index products other members added (when switched on) | Until you delete your account, or the product is removed |
| Your sports and the games you log | Until you remove the sport (the games you logged for it stay as your history until you delete them) or delete the game; deleted with your account |
| A coach's invites (when switched on) | Deleted the next time the coach saves, cancels, links or finishes setting up an invite, once it has been cancelled or has run out for 30 days, or has been set up for 30 days; one that has joined and is never set up stays; all deleted with the coach's account |
| A coach's planner items and reminder times | Planner items until the coach deletes them; reminder times are replaced as the app syncs the planner, and any more than a day old are cleared; all deleted with the coach's account |
| Payment records | Card payments: whenever a record is deleted, including when you delete your account, its money details (amount, dates, status, method and Stripe's reference numbers; not your name or notes) are kept in an archive for tax records and dispute evidence, [5 years: confirm the period]. Payments your coach recorded as paid or refunded are archived the same way when you delete your account. No automatic end is built yet. |
| Seller tax details some coaches gave us before 18 October 2026 | [To be settled] |
| Guest payers' name and email (payment links) | Blanked 12 months after the last payment, plan end or refund window |
| Payment-page IP codes | One day |
| Closed reports of payment links | One year |
| Notification subscriptions (a coach's coach-app devices too, up to five) | Until you turn notifications off, your browser cancels them, or a sixth device replaces the oldest |
| Record of notifications sent; daily usage counts | No automatic deletion today, and we have not yet set a period |
| Rest alerts (device address and keys, next exercise name) | Until the rest ends; anything left over is deleted automatically within about two hours. The day's count of rest alerts (under a coded reference) is cleared the next day |
| Waitlist | Until you ask us to remove it (email us); we have not yet set a maximum period |
| Lead page visit totals | Kept; they identify no one |
| Backups held by our database provider | How long they are kept is still to be confirmed |
If you delete your account (Me → Privacy & your data → Delete my account, when switched on; you confirm with your password and by typing DELETE), we first delete your photos and files from storage: progress photos, vision board pictures, and the videos and voice notes in your message threads, including ones your coach sent you. Then we delete your account and everything linked to it: your profile, logs, runs, sports, journal, messages, check-ins, AI Coach notes, consent records, notification settings, the problem reports you sent us and your answers about food index products. You leave your coach and any groups.
Until that is switched on, email us to delete your account and we do it by hand, the same way: we remove your photos and files from storage first, then your account and what is linked to it, with the same exceptions and the same waits.
What stays after your account is deleted:
- payment records: the money details only, as in the table above, and any instruction still needed to stop a card plan on Stripe;
- Stripe's customer record for you on your coach's Stripe account (your email address and payment history). Stripe and your coach hold it and we don't delete it; ask your coach or Stripe;
- technical records of card-payment updates we could not process straight away, kept so that no payment is lost track of. They hold no name or email;
- a record that you left your coach, with the date and who ended the coaching (no name). It counts towards your coach's business figures;
- consultation answers you sent a coach through their lead page. They are not linked to your account and stay until the coach deletes them; ask the coach or email us;
- your waitlist entry, if you joined the waitlist. It is not linked to your account; email us to remove it;
- products you added to the food index (when switched on), with their label photos and nothing that names you; ask us if you want a photo deleted;
- payment-link details that you gave under a different email address from your account, or while a refund or your 14-day cancellation period on them is still open. They follow the 12-month rule in section 8.
When deletion has to wait. The app tells you why and what to do. Your account can't be deleted while a monthly card plan with your coach is still running (cancel it under Payments first) or, with a coach you have left, is still being stopped; while a card payment you started is still open; while a card payment is being disputed; while your coach owes you a refund; or while your 14-day period to cancel a card payment is still open. A card plan that is already set to end stops on the day you delete. Coach accounts are closed by email.
12. Your rights
You have the right to:
- access your information and get a copy;
- have it corrected if it is wrong;
- have it deleted;
- restrict or object to how we use it;
- move it to another service (portability);
- withdraw consent at any time, without affecting what we did before;
- not be subject to decisions made only by automated means that have legal or similarly significant effects.
How to ask: email actiivclub@gmail.com from the email address on your account (or tell us how to confirm it is you). We reply within one month. If a request is complex we may take up to two more months, and we will tell you why. There is normally no charge.
In the app, under Me → Privacy & your data (when switched on), you can:
- download your information: your account's information as one file. Photos and files are listed, not included; you can save them from the app;
- see and delete what the AI Coach remembers about you, one note at a time or all at once;
- give or withdraw consent for your health details (section 5);
- delete your account (section 11).
Elsewhere in the app you can edit your profile; edit or delete journal entries, affirmations, to-dos, vision board pictures, progress photos, health and preference items, runs, measurements and your own workouts and exercises; switch notifications off; leave your coach; and cancel card plans under Payments.
By email, for anything else: for example deleting your account until the in-app route is switched on (section 11), a copy of your coach's private notes about you (they are not in the download), deleting single messages, correcting something you can't edit yourself, or restricting or objecting to how we use your information.
If you filled in a coach's consultation form, you can ask the coach to delete it, or email us.
13. Children and under-18s
Actiiv does not set a minimum age for the member app: nothing at sign-up checks how old you are, and your date of birth is optional. [A minimum age, and whether a parent's consent is needed under it, are still to be settled.]
What the app does today:
- Joining: the age choices when you join start at 18 to 24. Date of birth is optional and there is no age check at sign-up.
- The AI Coach: when the date of birth on your account shows you are under 18, the AI Coach does not suggest losing weight or dieting and keeps calorie goals above a minimum. Cycle tracking never shows the fertile window or ovulation under 18.
- Card payments: refused if the date of birth on your account shows you are under 18. If there is none on file, you confirm you are 18 or over when you pay.
- Payment links: people paying without an account must give a date of birth showing they are 18 or over. If a linked account's date of birth is later changed to under 18, the monthly plan is stopped and the first payment refunded.
- Consultation forms: you must confirm you are 18 or over, and the age choices start at 18.
- Sharing progress photos with a coach (section 4.7): only offered to members 18 or over by the date of birth on their account, and never to a member with no date of birth on file. If a date of birth under 18 has ever been saved on your account, sharing stays off until that date shows you are 18, even if the date is changed later; if it was a typing mistake, email us and we will check and correct it. A date of birth saved later that shows you are under 18 ends any sharing at once.
- Health-data consent (section 5, when switched on): only for members 18 or over. It is refused if the date of birth on your account shows you are under 18, and it ends if a date of birth saved later (for example when you set up your profile) does. If there is none on file, ticking the box confirms you are 18 or over.
- Coaches must be 18 or over under the coach terms (the app does not check this).
15. How we keep your information safe
- Every connection is encrypted (HTTPS).
- Our database checks, row by row, who is asking: you can read only your own information; a coach can read only the listed information of their current clients; public forms can only add information through checked functions and cannot read anything back.
- Photos, pictures and videos are kept in private storage, each person in their own folder, and shown through links that expire (one hour for your own photos, 10 to 30 minutes for message videos and voice notes). Progress photos you share with your coach are never given to them as a link: their app loads each one with their own login, checked every time.
- Our web servers do not hold a master key to the database. They act with the signed-in person's own permissions; scheduled jobs (notifications, payments) can only call a few narrow database functions protected by separate secrets.
- Seller tax details some coaches gave us before 18 October 2026 are encrypted (AES-256-GCM); the database holds only the encrypted text.
- Our logs are written not to contain names, email addresses or health details.
- Signing out removes your logs and profile from that device.
No system is perfectly secure. If a breach puts your rights at risk, we will tell you and the Information Commissioner's Office as the law requires.
16. Automated suggestions and alerts
The AI Coach and the coach Assistant make suggestions; people decide. Some checks are automatic:
- a meal plan containing one of your listed allergens is refused;
- card payments are refused if your date of birth shows you are under 18;
- your coach sees automatic alerts (section 4.9) to help them notice when you might need support.
None of these makes a decision about you with legal or similarly significant effects, as we understand it; this is still to be confirmed.
17. Links to other websites
Actiiv links to other websites, for example Stripe, Instagram and WhatsApp (used by coaches to share payment links), coaches' own pages, and shops listed in the Shop tab. Their own privacy notices apply.
18. Changes to this notice
We will update this notice when what we collect or how we use it changes, and show the date at the top. If a change matters to you, we will tell you in the app or by email before it applies.
19. Contact and complaints
Questions or requests: actiivclub@gmail.com, or write to FLIP OPERATING SYSTEMS LTD, 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF.
If you are unhappy with how we use your information, please tell us first so we can put it right. You also have the right to complain to the Information Commissioner's Office (ICO): https://ico.org.uk/make-a-complaint or 0303 123 1113.